In short: The comment documents specific local conditions in the Bitterroot National Forest and Ravalli County, including road mileage comparisons and observed invasive plant spread, while citing specific pages of the Roadless DEIS to argue that the proposed rule relies on top-down executive orders rather than local management.
Scored directly — The comment's whole text was scored on its own.
Scorecard
Each dimension is scored 0–3; the eight sum to the substance score out of 24.
- Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
- Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
- EA analysisEngages the agency's environmental analysis directly.
- Analytical gapIdentifies something the analysis fails to address.
- EvidenceBacks claims with specific facts, data, or research.
- RequestMakes a specific, actionable request of the agency.
- AlternativeProposes a different course of action.
- LegalCites statutes, regulations, or legal obligations.
How hard it is to set aside
A1 strong: Must be answered — it names the law.
Owed an answer on Evidence, Legal.
Standard dismissals it defeats
- Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
- Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
- Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
Still open to the agency
- Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
- Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
- Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
- Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
Topics
- Environmental Protection Biodiversity
- “Undeveloped roadless areas and Wilderness are part of what defines Montana”
- “Roads are detrimental to recovering animal species such as Grizzly Bears, Lynx, and Wolverines”
- “Roadless areas provide corridors for these animals to move about and expand their range”
- “Roads contribute to... the spread of invasive plants”
- Water Quality Quantity
- “Logging and mining can and does have negative effects on stream and river quality”
- Governance Policy Process
- “To me this sounds like an expansion of top-down management rather than bottom-up”
- “I support Alternative 1, no action”
- “repeatedly blocked from gaining wilderness status by conservative legislatures”
- Recreation Tourism Public Use
- “They are what makes our state the envy of people from all over our nation and the world”
- “Imagine if clearcuts or open mines were allowed around the perimeter of Glacier National Park”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisEvidence